Bashford, Terry

From:
Sent:
To:
Cc:
Kanter, Martha
Monday, April12, 2010 1 :55 PM
Yuan, Georgia
Shireman, Bob
Subject: Fwd: Kaplan, DeVry, EDMC Letter to Dep. Sec. Miller
Attachments: image003.jpg; ATT00001.htm; Kaplan, DeVry, EDMC Letter to Dep. Sec. Miller 4-12-10.pdf;
A TT00002.htm
[(b)(5)
l\lartfia Kanter
Under Secretary
U.S. Department of Education
"The future belongs to those who believe in the beauty of their dreams I"
--Eleanor Roosevelt
Begin forwarded message:
From: "AndrewS. Rosen" <andrew.s.rosen@kaplan.com>
To: "Miller, Tony" <Tony.Miller@ed.gov>
Cc: "Kanter, Martha" <Martha.Kanter@ed.gov>, "Shireman, Bob" <Bob.Shireman@ed.gov>,
"Fine, Stephanie" <Stephanie.Fine@ed.gov>, "Rebecca Campoverde"
<Rebecca.Campoverde@kaplan.com>
Subject: Kaplan, DeVry, EDMC Letter to Dep. Sec. Miller
Dear Tony:
Attached, in advance of our meeting on Thursday, is a letter on behalf of Kaplan, DeVry and
Education Management Corp. in response to your request for suggestions regarding the issue of
excessive student debt. We look forward to discussing these and other issues when we meet.
Best regards,
Andy
f cid:image003 .j pg@O 1 C9E81E.F A05B2301
AndrewS. Rosen
Chairman and CEO
Kaplan, Inc.
6301 Kaplan University Avenue
Fort Lauderdale, Florida 33309
(954) 515-3888
www.kaplan.com
The Honorable Anthony Wilder Miller
Deputy Secretary
U.S. Department of Education
400 Maryland Avenue, SW
Washington, DC 20202
Dear Secretary Miller:
April 12,2010
Thank you for soliciting input on the Department of Education's (ED) proposed Gainful
Employment (GE) regulation at our recent meetings. We are writing on behalf of our
institutions (Kaplan, DeVry, and Education Management Corporation), which together offer
opportunities for over three hundred thousand students to attend college annually. We are
deeply committed to educating and preparing our students for the new jobs of the 21st century,
and to ensuring that our students receive high-quality, results-oriented education, without being
burdened by excessive debt.
We understand and support what you are trying to accomplish. We believe that together we
can find a solution that addresses student debt and simultaneously enables the Administration
to achieve its goals of expanding access to quality higher education, particularly among non-
traditional students. We believe both sets of goals are achievable.
We thought it would be most helpful to (a) describe the contribution of the private sector in
achieving the Administration's goals, (b) explain the impact of the latest GE proposal made
public, and (c) offer a constructive alternative to this GE proposal that would address the ED's
concerns without restricting students' access to college opportunities.
Quality Private Sector Colleges Play A Critical Role in Achieving Administration Goals
President Obama has said he wants America to have the highest percentage of college
graduates in the world by 2020. This goal will require educating millions of additional college
students at a cost of many billions of dollars and cannot be met without the participation of
quality private sector colleges like ours. The private sector currently educates some 2. 7 million
students a year and has the resources to help alleviate the fmancial burden of achieving the
Administration's goal. Moreover, the private sector attracts more non-traditional students- a
critical requirement to increasing the number of college graduates.
The Honorable Anthony Wilder Miller
April 12, 2010
Page2
Not only do private sector colleges attract more non-traditional students, but we also help them
graduate and achieve gainful employment at significantly higher rates. A recent report by The
Parthenon Group, using ED data for public and private two-year and less institutions, shows
that students at private sector colleges graduate at rates roughly 50 percent higher than public
schools. The study further shows that private sector college students achieve higher percentage
wage increases (54% vs. 36%) after completing their education.
1
The Current GE Proposal Would Dramatically Limit Students' College Opportunities
Kaplan, DeVry, and EDMC share the ED' s goal of ensuring that students receive a quality
education and enter programs with a full understanding of the costs, without incurring
excessive debt. We would support regulation that appropriately addresses over-borrowing
while enabling high-quality institutions to continue their good work of building capacity and
innovation in higher education.
The GE criteria proposed by the ED at the end of the most recent Negotiated Rulemaking
session attempt to define "gainful employment" by establishing an 8 percent debt-service-to-
income threshold based on median student debt for college graduates. Income would be based
either on the Bureau of Labor Statistics (BLS) 25th percentile wage data, or actual earnings of
college graduates. Loan payments would be based on a 1 0-year repayment plan.
This proposal as written would have a number of unintended consequences. A recent study by
Mark Kantrowitz, a respected independent authority on fmancial aid, concludes:
"The 8% debt-service-to-income threshold is so strict that it would preclude for-profit
colleges from offering Bachelor 's degree programs. It would also eliminate many
Associate 's degree programs at for-profit colleges. Even non-frofit calleges would find
it difficult to satisfy this standard if they were subjected to it. "
Kantrowitz further found that:
"The proposed use of Bureau of Labor Statistics wage data ... will disproportionately
harm minority and female students. "
3
Kantrowitz also points out that the proposed GE rule tasks institutions with a job without
providing the tools necessary to complete the job:
1
Parthenon Perspectives on Private Sector Post-Secondary Schools, February 24, 2010, by Robert Lytle, Roger
Brinner and Chris Ross; p. 8; Source: NCES BPS 2004-2006.
2
What is Gainful Employment? What Is Affordable Debt?, Mark Kantrowitz, March 1, 2010, p. 1.
3
Ibid.
The Honorable Anthony Wilder Miller
April 12,2010
Page 3
"The debt-service-to-income threshold effectively establishes borrowing limits based on
field of study and degree programs, but does not give colleges the controls needed to
enforce these limits. Current sub-regulatory guidance precludes colleges from
establishing lower loan limits. "
4
Another study conducted by Charles River Associates reaches similar conclusions, estimating
that 18 percent of private sector programs will be disqualified from participation in Title IV
programs and that this would impact one-third of private sector students. This means that
hundreds of thousands of entering students would be displaced annually from private sector
colleges.
5
By 2020, approximately 5.4 million students who otherwise would be on track to
attend college would be denied access by the proposed GE regulation.
6
Finally, the GE proposal would result in significant job loss among the hundreds of thousands
of faculty members, administrators, and staff who work in the private post-secondary sector,
and in non-degree programs in public sector and independent schools as well.
Students Will Be Protected by Transparent Cost and Debt Information.
We remain concerned that defining "gainful employment" by student debt levels is beyond
Congressional intent. We believe that the necessary data to both defme the problem and
support a sufficient and informed policy have not yet been compiled and analyzed. We are
certain there are numerous consequences of the GE proposal that are not currently
contemplated by the ED.
For these reasons, we propose that student debt concerns be addressed by mandating that all
institutions disclose to students the information students need to make informed decisions prior
to taking on student debt, as well as warn students about programs that fail to meet a minimum
debt-service-to-income ratio under a new student consumer "lemon law." Prospective students
who receive sufficient information at the time of enrollment are in the best position to make an
informed decision regarding whether or not to attend an institution. We believe the information
students need to make decisions concerning the appropriate amount of debt to incur for a given
program should be provided in a disclosure form to students.
The form would include: (a) the cost of the program of study, (b) a reasonable projection of
potential earnings in the students' chosen field upon graduation and throughout the life of their
employment in that field, (c) a reasonable estimate of the debt students typically incur to
complete their program, and (d) students' repayment plan options. A proposed disclosure form
4
Ibid. p. 2.
s Report on Gainful Employment, Charles Rivers Associates, April2, 2010, prepared by Jonathan Guryan, PhD,
and Matthew Thompson, PhD, p. 38.
6
Executive Summary to Report on Gainful Employment, Charles Rivers Associates, Apri12, 2010, prepared by
Jonathan Guryan, PhD, and Matthew Thompson, PhD, p. 1.
The Honorable Anthony Wilder Miller
April12, 2010
Page4
is attached as Appendix 1. The accuracy of the information contained in the disclosure form
would be ensured by the misrepresentation prohibition that received tentative agreement at the
last Negotiated Rulemaking session. The proposed misrepresentation prohibition provides,
among other things, that:
If the Secretary determines an institution has engaged in substantial misrepresentation,
the Secretary may revoke or limit that institution' s participation in the Title IV
programs.
Misrepresentation is defined as any false, erroneous or misleading statement an
institution makes directly or indirectly to a student, prospective student, or any member
of the public, an accrediting agency, State agency, or the Secretary.
A misleading statement includes any statement that has the capacity, likelihood, or
tendency to deceive or confuse. The omission of information may also be interpreted as
a misrepresentation.
In addition to this disclosure, schools would be required to warn students prior to enrollment of
any program that fails to meet a debt-service-to-income ratio test. The debt-service-to-income
ratio would be based on the approach recently proposed by the ED, with appropriate
modifications discussed below. Institutions offering programs that fail the test would be
required to warn students in appropriate marketing materials, and in a written disclosure signed
by the student prior to enrollment, that (a) the program has failed a debt-service-to-income-
ratio test, and (b) student borrowers enrolling in the program should expect to have difficulty
meeting their repayment obligations upon graduation.
To ensure that the debt-service-to-income ratio is appropriately directed at identifying "outlier"
programs we propose that the ratio currently contained in the GE proposal be adjusted as
follows:
Formula applied to non-degree programs only.
};:> Degree programs confer lifetime benefits that don't correlate easily to
specific job codes, such as higher lifetime earnings, higher income growth
rates, greater employability, better career advancement and job stability.
7
In
addition, degree holders tend to change jobs and pursue careers seemingly
unrelated to the degrees, but using the skills they developed in college.
Including degrees in the ratio definition would dramatically undervalue these
programs.
};:> By applying the formula only to non-degree programs, both private and
public institutions are impacted in the same manner.
A debt-service-to-income threshold of 15 percent, based on median student debt for
college graduates, and assuming a current unsubsidized Stafford loan interest rate of
6.8% to calculate the annual repayment amount.
7
Kantrowitz, pp. 20-21.
The Honorable Anthony Wilder Miller
April 12, 2010
Page 5
)- The 15 percent debt-service-to-income threshold is referenced in the
Kantrowitz study as a well as a recent study published by the College
Board,
8
and is within the range generally used by personal fmancial
counseling professionals.
Income based either on the BLS 50th percentile wage data, or actual earnings of
graduates if the latter are higher than the BLS 50th percentile.
)- The 50th percentile of the BLS wage data more accurately reflects the long-
term potential earnings of a graduate. Moreover, there is no reason to
assume that non-degree program graduates, regardless of their backgrounds,
would be unable to achieve average earnings.
Loan payments based on a 20-year repayment plan.
)- The 20-year loan repayment plan is also referenced in the Kantrowitz study
and supported by the fact that borrowers are permitted to, and do, choose
repayment plans covering a period of up to 25 years.
Exclude prior school debt from the calculation and provide institutions the
regulatory ability to control student borrowing, thereby enabling compliance with
ratio and 90/ 10 requirements.
)- Absent the regulatory ability to control student borrowing, the GE
calculation should be based only on direct cost of education.
Eliminate the ED pre-approval requirement for new programs.
)- State regulatory bodies and accrediting agencies already require approval of
all new programs.
We also recommend that the ED consider alternative routes to compliance with the debt-
service-to-income ratio test, specifically by establishing: (1) target graduate cohort default rates
(GCDRs) (e.g., 12.5% GCDR on a two-year calculation; 15% on a three-year calculation), (2)
targets for actual post-graduation salaries that include a multiplier of 1.5x to recognize the fact
that lifetime earnings are significantly higher than BLS rates, and (3) thresholds for post-
graduate employment rates.
We believe that the proposal contained in this letter provides an innovative and effective way to
protect students from institutions that over promise and under deliver to students, thus leaving
students with too much debt and not enough return on investment.
8
How Much Debt Is Too Much, Sandy Baum and Saul Schwartz, The College Board, 2006, p. 12.
The Honorable Anthony Wilder Miller
April 12, 2010
Page6
We appreciate the opportunity to provide this input and we look forward to sitting down with
you soon to discuss these matters further.
Yours Truly,
Andrew S. Rosen
Chairman and CEO, Kaplan, Inc.
Daniel Hamburger
President and CEO, DeVry Inc.
Todd S. Nelson
CEO, Education Management Corporation
Enclosures
cc: The Honorable Martha J. Kanter
Mr. Robert Shireman
APPENDIX 1
INSTITUTIONAL DISCLOSURES RELATED TO EXPECTED EARNINGS AND DEBT
You have requested information about our ___ program
Program Level: 0 Associates [g)Bachelors 0Masters Ocertificate/Diploma
Here are some important disclosures for the award year ending June 30, 2010
During the year ended June 30, 2009 , 75.8 %of students enrolled in this program graduated or
continue to be actively enrolled at the institution while 24.2 % ceased enrollment.
Of the students who graduated, 88.6 % were employed in their field of study, or a related field,
within six months of graduation with an average annual salary of approximately$ 46,300 per year.
This academic program corresponds to the following Standard Occupational Classification (SOC}
codes as reported by the Bureau of Labor Statistics (BLS): . The weighted annual
salaries for these SOC codes at the 25th and 75th percentiles are $ 45,900 and $ 78,210 .
respectively. For information related to salaries from these and other occupations, please visit
http:llwww.bls.gov/oeslcurrentloes_nat.htm.
The cost of this program of study for a student enrolled full-time and with no transfer credits is
$ 62.040 . The average annual tuition increase for the most recentl y concluded three years was
4.6 %
The average education loan debt of students incurred at this institution and who graduated from this
program during the prior award year was $ 33,100 . This amount includes $ 30,900 of federal
student loan debt and $ 2.200 of institutional loan debt. This does not include any debt incurred
while attending another institution. Additionally, 4.6 %of graduates obtained private student loans
from third parties.
If this average education loan debt was 100% federal loans with an average interest rate of 6.8% and
you chose to repay using a 10 year standard repayment term, the annual total of 12 monthly
payments would be$ 4,571.04 . If you chose to pay using a graduated repayment plan (over 10
years), the total of your first 12 monthly payments would be $ 3,138.60 . For more information
concerning repayment options on federal loans, please visit
https :I I stud entloans.gov I myDi rectLoa n/i ndex.action.
The latest official Cohort Default Rate (FY07) from the US Department of Education indicates that
1.7 % of graduates in this program defaulted on their federal loans.
PLEASE NOTE THAT YOUR ACTUAL EXPERIENCE MAY BE DIFFERENT THAN THE AVERAGES AND
STATISTICS PRESENTED ABOVE.
Bashford, Terry
From:
Sent:
To:
Subject:
Attachments:
(b)(5)
Georgia
From: Erceg/ Marta
Yuan, Georgia
Wednesday, April 28, 2010 7:06 PM
Erceg, Marta
RE: Media reports - background for noon meeting
Post-Secondary_Education-201 00413.pdf
Sent: Wednesday/ April 28
1
2010 7:02PM
To: Yuan/ Georgia; Mitchelson/ Mary
Subject: Fw: Media reports- background for noon meeting
(b)(5)
From: Rogers/ Margot
To: Erceg/ Marta
Sent: Wed Apr 28 11:02:21 2010
Subject: FW: Media reports- background for noon meeti ng
From: Yuan
1
Georgia
Sent: Wednesday/ April 28
1
2010 11: 12 AM
To: Clark/ Teresa
Cc: Rosenfelt
1
Phil; Rogers/ Margot
Subject: Media reports- background for noon meeting
Teresa-
l(b)(S)
Georgia Yuan
DeVry leads ed. stocks lower as Credit Suisse downgrades on regulatory, job market concems
Associated Press
04/26/ 10 9:30AM PDT
NEW YORK- DeVry led decliners in education stocks Monday after a Credit Suisse analyst said the for-profit school could
be hurt by proposed regulatory changes and an improving job market that could slow enrollment.
The administration has pushed hard for gainful employment regulations, which stipulate that graduates of schools must not
spend more than 8 percent of their income on paying student loans.
It's meant to help improve school quality- maki11g sure students are qualified and the courses help increase their incomes-
as student loru1 defaults soar.
If schools failed to pass this test, the govemment could block their access to federalloru1s for students, the bulk of their
revenues.
In early April, the Education Department said schools with 50 percent graduation rates and 70 percent job placement rates
would be exempt from a proposed rule linking graduates' incomes to required debt payments.
Analyst Kelly Flynn, however, said Washington sources believe the more lenient proposal might not wind up in a draft of the
law that will be posted by mid-May or Jtme.
Flynn downgraded DeVry and ITT Educational Senrices Inc. to "neutral" from "outperform," cutting target prices to $65 from
$75 and $110 from $135, respectively.
Shares ofDeVry Inc. fell $4.59, or 6.6 percent, to $64.87, while ITT stock dropped fell $2.07, or 1.8 percent, to $109.71.
Shares of Apollo Group Inc. , which nms the largest for-profit school, the University of Phoenix, also slid 93 cents, or 1.5
percent, to $62.60, while Corinthiru1 Colleges Inc. stock fell 59 cents, or 3.3 percent, to $17.30. Career Education Corp. fell 61
cents, or 1.8 percent, to $33.49 and Strayer Education Inc. dropped $2.54, or 1 percent, to $250.49.
Meanwhile, Flynn cited DeVry's warning on slower enrollment growth in one of its divisions and ITT's waming on higher
advertising spending.
For-profit schools have seen big gains in enrollment because of the recession ru1d high tmemployment. As the job market
improves, people may not feel as much as a need to bolster their resmnes.
APRIL 26, 2010, 10:57 A.M. ET
Debt, Job Rule Uncertainty Hits Shares Of For-Profit Colleges
NEW YORK (Dow Jones)--A government proposal to hold colleges accountable for graduating students with high debt
loads and low income levels came front and center, again, after Credit Suisse analysts reversed their assumption that the
Department of Education had softened its stance on the subject.
Monday morning, Credit Suisse issued a note saying the Department of Education has returned to a stiffer set of rules on
post-graduation debt and gainful employment levels that colleges must meet. The news hit share prices of for-profit
universities that had rallied on expected softer rules.
Credit Suisse downgraded ITI Educational Services Inc. (ESI) and DeVry Inc. (DV) to neutral from outperform and
slashed their price targets, citing the potential fallout from thei r new take on gainful employment as well as concerns of
countercyclicality. ITT recently was off 2.9% to $108.53, while DeVry was down 6.5% to $64.96. Credit Suisse had
upgraded the schools two weeks ago.
Other for-profit schools, including Strayer Education Inc. (STRA), Career Education Corp. (CECO) , Corinthian Colleges
Inc. (COCO) and Apollo Group Inc. (APOL), were also trading down.
2
The Department of Education originally said schools could face scrutiny that could put federal assistance--often the
primary revenue stream for for-profrt colleges--at risk if they did not have at least a 70% graduation rate and 70% job
placement in field of study. Two weeks ago, Credit Suisse, and others, sent out notes saying they believe the Department
of Education had softened the graduation level to 50%, sending shares higher, with some hitting 52-week highs.
"Oddly, we suspect the big upward move the stocks had when the investment community found out about the 50%
exemption may have led to pressure on the DOE to remove the 50% exemption," the firm wrote Monday.
Some education insiders have had mixed feelings on predicting the gainful-employment measure, arguing that it's
improper to say what the Department of Education will put forth and it's best to wait until the official proposal is released
for public comment. That will happen by mid-June.
"I'm not sure who thinks they have what access to what's in this draft," said one for-profit school official, but "I would really
not be jumping to any conclusions just yet." He said there's no way of knowing "whether it's been hardened, softened,
pureed, whatever."
Representatives from the Department of Education weren't immediately available for comment.
http://online.wsj.com/article/BT-C0-20100426-710339.html?mod=rss Hot Stocks
Georgia Yuan
Deputy General Counsel
Postsecondary Education and Regulatory Service
U.S. Department of Education
400 Maryland Avenue SW 6E341
Washington, DC 20202
202-401-6000
3
April 13, 2010
Trace Urdan
turdan@signalhill.com
415.364.0365
SignaR HiRR
Business Services - Education Services
Industry Update
Relief: Gainful Employment Gains Alternative Measure
Our Call :
As anticipated, Department of Education (USDOE) draft regulations went to the Office of
Management & Budget (OMB) last Friday 4/9 for review prior to their publication in the Federal
Register -- likely 5/15. A credible source close to OMB tells us that while the 8% median
debt/income measure, and the 90% student loan repayment measures appear to be essentially
unchanged from the terms presented by the USDOE in January, a third alternative measure has
been added. This measure would allow programs with a graduation rate of 50% or better and a
subsequent job placement (in the relevant field) of 70% or better to qualify out of the other two
measures.
Though the devil will certainly be in the details, including how these items are to be considered
for students that are transferring credits and may be already employed, the new measure
effectively removes the significant threat the rules had created for nationally-accredited degree
programs with typically high default rates. The new measure, in fact, seems to closely resemble
rules already imposed by national accrediting bodies. And while we might anticipate that the
terms could be stricter in USDOE's conception, they should be eminently achievable with
minimal disruption for all programs.
According to USDOE analysis, (in process of being reviewed by OMB,) the rules themselves
would only affect 6-8% of all for-profit programs, with culinary, automotive tech, and nursing
programs hardest hit. (We note that this seems out of keeping with our knowledge of these
programs as represented by publicly-traded schools, but nevertheless appears to represent a
conclusion reached by USDOE.) Our contact indicated that the University of Phoenix (NASDAQ:
APOL; Buy) was not seen as affected at all in the USDOE analysis.
While we expect all post-secondary school stocks to benefit from the news, we believe that the
those names that had been most challenged by the existing terms are likely to see the biggest
benefit as a result of the change. These include ITT Educational Services (NYSE: ESI ; Buy) ,
Corinthian Colleges (NASDAQ: COCO; Buy), and Career Education (NASDAQ: CECO; Buy)
which recently heralded graduation rates comfortably above 50%. Though some individual
programs may still fail all three tests, we believe these are likely to be isolated, rare and fixable.
We view this apparent concession as evidence of a desire by Secretary Duncan to defuse what
was promising to be an area of real contention, as evidenced by House Republicans, members
of the Congressional Black Caucus, and Senator Lamar Alexander all calling out the Secretary
on this issue. Secretary Duncan needs, in our opinion, a diverse coalition of supporters to pass
his signature issue: K-12 education reform. Because the Secretary's K-12 proposals do not
easily fall within typical party boundaries, he really does need a bipartisan coalition in both the
House and Senate education committees to pass his version of ESEA (NCLB) . No concession
at all would have kicked off a loud and publicized summer of public commentary. Because it is
very difficult to argue that a 50% graduation rate and a 70% employment rate is an onerous
burden, we think USDOE has effectively neutered the campaign to ditch the rule entirely.
We still expect industry to challenge the rule in public and likely later in court, but based on our
reliable source, we believe investors need no longer fear that significant revenues could be at
risk in the event that the rules are passed.
Please see important disclosure information on page 2 of this report.
April13, 2010
Important Disclosures
Analyst Certification
I, Trace Urdan, hereby certify that all of the views expressed in this research report accurately reflect my
personal views about the subject securities or issuers. I also certify that no part of my compensation was, is or
will be directly or indirectly related to the specific recommendations or views expressed in this research
report.Signal Hill does not compensate its equity research analysts based on specific investment banking
transactions. Signal Hill Equity research analysts receive compensation based on several factors, including
overall profitability and revenues of the firm, which include investment banking revenues.
Meaning of Ratings
Signal Hill uses a three-tiered rating system defined as follows:
BUY: We expect this stock to outperform its peers over the next 12 months:
HOLD: We expect this stock to perform in line with its peers over the next 12 months:
SELL: We expect this stock to underperform its peers over the next 12 months:
Rating
BUY
HOLD
SELL
Disclaimer
Distribution of RatingsiiB Services
Signal Hill
Count
77
47
1
Percent
61.6
37.6
0.8
18 Serv.lPast 12 Mos.
Count
72
38
Percent
93.5
80.9
100.0
This report has been prepared using sources we deem to be reliable but we do not guarantee its accuracy and
it does not purport to be complete. This report is published solely for information purposes and is not intended
to be used as the primary basis for making investment decisions, which should reflect the investment objectives
and financial situation of the investor: The opinions expressed herein are subject to change without notice. This
report is not an offer or the solicitation of an offer to buy or sell securities. Additional information is available
upon request.
Post-Secondary Education 2
Bashford, Terry
From:
Sent:
To:
Cc:
Subject:
Attachments:
(b)(S)
Manheimer, Ann
Wednesday, April 07, 2010 6:07PM
Madzelan, Dan; Bergeron, David
Shireman, Bob; Yuan, Georgia; Dannenberg, Michael; Arsenault, Leigh; Picoult, Francine;
Smith, Kathleen; Manheimer, Ann
Neg Reg Update and Next Steps
GE 2.ppt
(b)(S)
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
Q)
()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(5)
N
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
Q)
()
oe
Wa_
<.9
w
.....J
>
a::
a..
7b}(5)
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
Q)
()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(S)
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
I Q)
I ()
oe
Wa_
<.9
w
.....J
>
a::
a..
L()
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
I Q)
I ()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(S)
<0
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
Q)
()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(5)
Q)
>
+='
ro
!.....
Q)
.0
Q) C/)
OC/)
Q)
()
oe
UJa_
<.9
UJ
.....J
>
a::
a..
_j
(b)(S)
co
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
I Q)
I ()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(5)
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
I Q)
I ()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(5)
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
Q)
()
oe
Wa_
<.9
w
.....J
>
a::
a..
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
Q)
()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(5)
'{b)(5)
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
Q)
()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(5)
Q)
>
+J
ro
!.....
Q)
.0
Q)
0 ~
Q)
()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(5)
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
Q)
()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(5)
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
I Q)
I ()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(S)
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
Q)
()
oe
Wa_
<.9
w
.....J
>
a::
a..
'(b'j{S)
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
Q)
()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(5)
0
N
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
Q)
()
oo
wQ:
<.9
w
.....J
>
a::
c..
(b)(5)
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
Q)
()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(5)
N
N
Q)
>
+J
ro
!.....
Q)
.0
Q)
0 ~
Q)
()
oo
wQ:
<.9
w
.....J
>
a::
c..
(b)(5)
-
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
Q)
()
oe
Wa_
<.9
w
.....J
>
a::
a..
Bashford, Terry
From:
Sent:
To:
Cc:
Subject:
Attachments:
Thanks,
Georgia
From: Finley, Steve
Yuan, Georgia
Tuesday, April 06, 2010 6:07PM
Finley, Steve
Jenkins, Harold; McFadden, Elizabeth; Higgins, Shannan; Sann, Ronald
RE: Next steps on gainful employment
Gainful Employment- Secretary briefing (2).doc; GE 2.ppt
Sent: Tuesday, April 06, 2010 4:09PM
To: Yuan, Georgia
Cc: Jenkins, Harold; McFadden, Elizabeth; Higgins, Shannan; Sann, Ronald
Subject: Next steps on gainful employment
Georgia--
(b)(5)
Steve
(b)(5)
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
Q)
()
oo
wQ:
<.9
w
.....J
>
a::
c..
N
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
I Q)
I ()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(5)
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
I Q)
I ()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(5)
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
I Q)
I ()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(5)
L()
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
Q)
()
oo
wQ:
<.9
w
.....J
>
a::
c..
(b)(5)
<0
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
I Q)
I ()
oe
Wa_
<.9
w
.....J
>
a::
a..
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
Q)
()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(5)
co
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
Q)
()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(5)
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
I Q)
I ()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(S)
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
Q)
()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(S)
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
Q)
()
oe
Wa_
<.9
w
.....J
>
a::
a..
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
I Q)
I ()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(S)
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
Q)
()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(5)
(b)(S)
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
I Q)
I ()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(5)
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
I Q)
I ()
oe
Wa_
<.9
w
.....J
>
a::
a..
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
I Q)
I ()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(5)
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
Q)
()
oe
Wa_
<.9
w
.....J
>
a::
a..
0
N
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
I Q)
I ()
oe
Wa_
<.9
w
.....J
>
a::
a..
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
I Q)
I ()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(5)
N
N
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
I Q)
I ()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(5)
Gainful EmQiovment
~ ~ - - - - - - - - - - - - - - - - ~
1
(b)(S)
2
(b)(5)
3
Bashford, Terry
From:
Sent:
To:
Cc:
Subject:
Attachments:
Shireman, Bob
Tuesday, April 06, 2010 4:59PM
Arsenault, Leigh; Manheimer, Ann
Yuan, Georgia; Dannenberg, Michael
revised deck
GE 2.ppt
Robert Shireman, Deputy Undersecretary
U.S. Department of Education
400 Maryland Ave., S.W.
Room 7E310
Washington, D.C. 20202
(202) 260-0101
Fax: 202-205-0063
bob.shireman@ed.gov
(b)(5)
Q)
>
+J
ro
!.....
Q)
.0
Q)
0 ~
Q)
()
oo
wQ:
<.9
w
.....J
>
a::
c..
(b)(5)
N
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
Q)
()
oe
Wa_
<.9
w
.....J
>
a::
a..
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
I Q)
I ()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(5)
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
I Q)
I ()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(5)
L()
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
Q)
()
oo
wQ:
<.9
w
.....J
>
a::
c..
(b)(5)
<0
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
I Q)
I ()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(5)
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
Q)
()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(5)
co
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
I Q)
I ()
oe
Wa_
<.9
w
.....J
>
a::
a..
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
I Q)
I ()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(5)
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
Q)
()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(S)
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
Q)
()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(5)
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
Q)
()
oe
Wa_
<.9
w
.....J
>
a::
a..
[{b)(S)
L
_j
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
Q)
()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(5)
(b)(5)
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
I Q)
I ()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(5)
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
I Q)
I ()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(5)
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
I Q)
I ()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(5)
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
I Q)
I ()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(5)
0
N
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
I Q)
I ()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(5)
I
J
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
Q)
()
oe
Wa_
<.9
w
.....J
>
a::
a..
(b)(S)
N
N
Q)
>
+J
ro
!.....
Q)
.0
Q) C/)
OC/)
I Q)
I ()
oe
Wa_
<.9
w
.....J
>
a::
a..